As we continue to grind our way through the Covid-19 pandemic, everyone’s patience and optimism struggles. However, there are some encouraging signs that both the number of cases and the burden of serious disease and deaths due to Covid is finally beginning to decline.
Further, the flu season is all but negligible in comparison to past years. This is great news.
What does this mean for pilots and the general population? My conclusion is that while some early optimism might be emerging, we must remain on high alert and continue all public safety and infectious disease recommendations as per the Centers for Disease Control and Prevention (CDC) and federal, state, and local governments.
Pilots want to know the latest and greatest updates from the FAA in regard to Covid policies, protocols, and, of course, the coveted medical certificate extensions. The basic exemptions for both operational and medical protocols is as per SFAR 118, which has been modified twice since it was initially published on April 29, 2020, and currently extends through April 30, 2021.
The most current update to the medical extension policy pertains to medical certificates expiring from October through last month. These may now be extended for an additional two calendar months (three months for pilots residing or operating primarily in Alaska).
As of this writing, the FAA has not stated any intention to permit additional medical exemptions under the SFAR, so this aspect of today’s discussions could become a moot point in the coming months.
There remains significant confusion about whether a pilot may use a medical certificate extension more than once. Permit me to clarify it here—by further confusing the situation. One aspect is simple, fortunately: an individual medical certificate can only be extended once. Easy enough, so far.
The question remains, however, whether a pilot who has used the extension on a previous medical certificate can use it again on a subsequent medical certificate issuance. I have had a comprehensive discussion with the FAA Aeromedical Certification Division (AMCD), and the answer to the question of utilizing an extension on a subsequent medical certificate is a resounding “maybe.”
There really is no formal guidance for this, so here’s what the AMCD policy is currently: an extension for a subsequent medical certificate is neither automatic nor guaranteed. Such requests could be considered on a case-by-case basis, but it would be best to have a good reason to ask for an extension of a subsequent medical certificate (if the prior medical certificate was indeed extended).
This process would be similar to that being used for special issuance medical certificate extensions. However, in most cases it would be simpler to just renew the medical certificate on time.
It would take the pilot, the AME, and the FAA more time and hassle to accommodate a request for an additional extension than it would be to simply go to the AME and obtain a current medical certificate at the appropriate time. If the AME had time to interface with the FAA to request an additional exemption, then more likely than not that AME has the time to do an exam and issue the pilot a new medical certificate.
The first medical certificate for which a pilot wishes to use an extension is done so automatically, without the need for FAA interface. To do so again, on a subsequent medical certificate, is clearly not an automatically guaranteed accommodation. Be very careful about this to ensure that you do not operate in violation of medical certificate duration FARs.
The FAA has no intention of causing any pilot to become grounded for purely logistical reasons. Hence, it is not lost on the FAA that some AMEs are not as available as they once were, due to changes in the industry and their medical practices secondary to Covid.
If a pilot is simply unable to obtain the subsequent medical certificate in compliance with the usual medical certificate durations as per the FARs, then an accommodation might be possible on a case-by-case basis. This would entail direct contact with an FAA medical officer at the AMCD.
My most recent conversations with the FAA, as well as many pilots and other AMEs, leads me to believe that there is sufficient AME availability currently to accommodate most pilot requests for on-time medical certificate issuances.
That said, you have already read some of my previously stated disclaimers and occasional dismay at some of the more confusing aspects of the medical extension policy when it was first issued, and this discussion brings about yet more potential confusion, unfortunately. Please remember that the FAA continues to publish a statement on its website that pilots should accomplish their FAA medical exams on schedule if at all possible. Aviation advocacy groups such as the Air Line Pilots Association have also stated that recommendation, and continue to do so in ongoing publications.
The purpose of the original extensions was primarily to provide relief for pilots truly unable to update their FAA exams, either because their AMEs were unavailable or because they were unable to obtain required documentation for specific medical conditions due to lack of availability of their continuity physicians. That situation is, for the most part, rectified at this time.
I have kept my AME office open throughout the pandemic, so my pilot clients have not had any scheduling difficulties. I have also been fortunate in that my clients have been able to obtain all of their required medical documentation if they are being followed under special issuance authorizations.
For pilots unable to locate an AME or obtain required medical documentation at no fault of their own, the medical exemptions have been instrumental in keeping them on flight status during this confusing and difficult time.
However, an automatic initial extension does not apply to all medical certificates. For example, time-limited medical certificates issued under a special issuance authorization are not automatically extended.
If the medical certificate has a “Not valid after (date)” limitation on it, it expires as per that limitation. But, on a case by case basis, it is possible to obtain a one-time extension.
This is not a simple process for the AME to achieve, so most of the time it is best to obtain the special issuance data and renew the medical certificate on time. Once again, if that is not possible, the FAA likely will grant an exemption to this. The FAA discusses this policy in somewhat nebulous wording in the Covid discussions on its website.
The FAA has formally issued guidance regarding the two currently available vaccines (Moderna and Pfizer). These vaccines are not truly “approved,” but they have each been made available through an Emergency Use Authorization (EUA).
Thus, the FAA permits pilots to receive these vaccines so long as a 48-hour waiting period is observed before flying—and, as per FAR 61.53, which guides all medical decisions, the pilot is also feeling fit to fly. As other vaccines obtain either formal approval or become available through EUAs, it is expected that they too will fall under this general policy.
What have you heard about the influenza (flu) season this year? Almost nothing, right? Reviewing the CDC website multiple times recently, I have been astounded at how minimal the disease burden of the flu has been in the 2020 to 2021 season. In fact, it is noted that the impact of the flu this season is “too low” to be able to provide much statistical predictive data.
A state-by-state map of flu cases shows that no state has more than “minimal” flu impacts. The statistical changes in comparison to previous years are striking, and are almost too difficult to comprehend or believe at first glance.
However, the facts are clear—there are very few cases of the flu this year. I will not bore you with the specifics, but suffice it to say that it’s worth a few minutes of your time to peruse the CDC website from time to time.
Virtually all of the infectious disease-related pneumonia deaths have been due to Covid, not the flu.
Why do you think this is? One hypothesis, of course, is that the Covid-prevention strategies are indeed successful in reducing disease transmission. Obviously, we have no previous multiyear ongoing annual Covid data to compare with, but there are many years of continuous flu-monitoring statistics to consider.
While nobody enjoys that restaurants and schools have largely been closed, and certainly it is impersonal for all of us to be wearing face masks in public places, in the short term it appears that these strategies are quite effective in reducing disease transmission. Let’s hope that if disease impacts continue to lessen that, in time, we will again see our economy, schools, airlines, restaurants, and social structures begin a strong recovery.
The CDC recently issued a statement that wearing either tight-fitting masks, or double masking, can reduce virus transmission by well over 90 percent. That is an impressive success story, especially considering how simple the solution is. Wearing face masks is inconvenient, sure, but well worth the effort.
The decline in total cases and disease impacts is perhaps a first sign of potential long-term lessening and relief from the pandemic. It will not go away overnight, of course, but little by little progress is being made.
Contributory factors also include the increased availability of vaccines, with additional groups of at-risk age and occupational stratification tiers now finally receiving their vaccinations. Of course, there are also many people who tested positive for Covid who fortunately have recovered and have some natural immunity.
It is not known yet how long the immunity will last—whether from natural or vaccination-induced immune system responses—so it remains conceivable that annual booster shots might be recommended along with the routine annual flu booster.
The newer Covid variants are creating puzzling complications to this entire picture. All viruses are crafty, and they mutate as needed to survive. This is why there is an annual update to the flu vaccine.
However, the Covid variants seem to be particularly adept at evading efforts to provide immunity against them, hence making them more contagious than the original virus. The CDC and infectious disease research agencies are working as fast as possible to learn about these new variants and determine how to best deal with them over time. It is clear that, for now anyway, we can’t let our guard down, and we should continue with the recommended mitigation strategies.
The CDC also recently published a statement that persons who have received a full vaccination regimen are no longer required to quarantine after a known Covid exposure. While this sounds great, I think it still behooves people to continue to take the preventive measure strategies seriously, and the CDC indeed has published guidance supporting that assumption.
It is possible that airlines and/or corporate flight operations could elect to enact more restrictive individual policies, much as many of them do in regard to the “bottle to throttle” FARs regarding alcohol consumption.
On a final note, the FAA has announced that Susan Northrup, MD, MPH, has been appointed as the new Federal Air Surgeon. Dr. Northrup has impressive credentials, including being both a private pilot and retired USAF Colonel. She was deployed during both Operations Desert Storm and Desert Shield, and has also served as the FAA Senior Regional Flight Surgeon for the Southern Region.
Her credentials and experience are impressive and are too numerous to mention in this writing. I am optimistic that Dr. Northrup will provide effective aerospace medical management strategies for the FAA.